Datalign Advisory, LLC
Effective: December 21, 2021
Our Commitment to You
Datalign Advisory, LLC (“Datalign”) is committed to safeguarding the use of your personal information that we have as your Investment Advisor. Datalign (referred to as "we", "our" and "us" throughout this notice) protect the security and confidentiality of the personal information we have and make efforts to ensure that such information is used for proper business purposes in connection with the management or servicing of your account. Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything we can to maintain that trust.
We do not sell your nonpublic personal information to anyone. Nor does Datalign provide such information to others except for discrete and proper business purposes in connection with the servicing and management of your account as discussed below.
The Information We Collect About You
You typically provide personal information when you complete the paperwork required to become our Client. This information may include your:
|• Name and address|
|• E-mail address|
|• Phone number|
|• Social security or taxpayer identification number|
In addition, we may collect nonpublic information about you from the following sources:
- Information we receive in the course of establishing a customer relationship including, but not limited to, applications, forms, and questionnaires.
- Information about your transactions with us or others.
Information about You That Datalign Shares
Datalign works to provide products and services that benefit our customers. We may share nonpublic personal information with non-affiliated third parties as necessary for us to provide agreed services and products to you consistent with applicable law. We may also disclose nonpublic personal information to other financial institutions with whom we have joint business arrangements for proper business purposes in connection with our services to you. In addition, your nonpublic personal information may also be disclosed to persons we believe to be your authorized agent or representative, regulators in order to satisfy Datalign’s regulatory obligations, and as is otherwise required or permitted by law. Lastly, we may disclose your nonpublic personal information to companies we hire to help administrate our business. Companies we hire to provide services of this kind are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of your personal information to the performance of the specific service we have requested.
To repeat, we do not sell your nonpublic personal information to anyone.
Information about Former Investors
Datalign does not disclose, and does not intend to disclose, nonpublic personal information to non-affiliated third parties with respect to persons who are no longer our clients.
Confidentiality and Security
Our employees are advised about the firm's need to respect the confidentiality of our customers' nonpublic personal information. Additionally, we maintain physical, procedural and electronic safeguards in an effort to protect the information from access by unauthorized parties.
We'll keep you Informed
- Collecting Your Information. We may collect information about you in a variety of ways. The types of information we may collect via the Site include, but are not limited to:
- Demographic and other personal information you choose to provide in connection with completing an online form, providing content on the Site, or other activities in which you participate on the Site, such as your name, age, phone number, location and financial information.
- If you arrive at the Site by “clicking through” from an email or other website, certain information about you that you provided to that email sender or other website, such as the terms you were searching that led you to the Site.
- Information our servers automatically collect when you visit, use, or browse the Site, such as your IP address, your operating system, browser version, the address of a referring website, the pages you visit on the Site, the dates and times you visit the Site, device and usage information, such as language preferences, referring URLs, country, location, information about how and when you use our services and other technical information. This information is primarily needed to maintain the security and operation of our services, and for our internal analytics and reporting purposes.
- If you access the Site from a mobile device, information about the type of mobile device you use.
- Information about you from third party sources that we contract with for the purpose of verifying the contact information you provided to the Site and other third parties, including data aggregators and public databases.
- Using Your Information. We may use any information collected about you via the Site to: help increase the efficiency and operation of the Site; deliver and improve our products and services; manage our business; monitor and analyze usage and trends to improve the Site and the user experience; generate a personal profile of you to make future visits to the Site more personalized; perform the functions and services you request; send you confirmations, updates, alerts, administrative messages, and otherwise facilitate your use of the Site; request feedback and contact you about your use of the Site; respond to your emails; compile anonymous statistical information and analyses, which we may use internally and/or provide to third parties; and deliver information to you that you request or that we think may be of interest to you, such as articles, news, or information about various promotions.
- Sharing Your Information. We may share your information as follows:
- We may share your information with third parties that perform services for or on our behalf.
- We may share your information as permitted or required by any applicable law in response to a subpoena or other legal process or as we deem necessary to investigate or remedy any actual or potential violation of our policies or to protect the rights, property, and safety of datalignadvisory.com or others, as we deem appropriate.
- We may allow selected third parties to use tracking technology on the Site, which will enable them to collect information about how you use the Site over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.
- Security of Your Information. While we take reasonable steps to protect any personally identifiable information you choose to provide via the Site from unauthorized access, please be aware that, despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online can potentially be intercepted and used by unauthorized parties, so please keep this in mind when disclosing any personal or personally identifiable information via the Site. To help ensure security via the Internet, we recommend you keep your browser up to date with automatic security updates enabled.
- Policy for Children. We do not use the Site to solicit information from or market to children under the age of 18. By using the Site, you represent that you are at least 18 years of age. We encourage parents and legal guardians to monitor their children’s internet usage and to instruct their children to never provide personal information through the Site or any other website without parental consent. If you believe a child has provided personal information to us via the Site, please contact us and we will use reasonable efforts to locate and delete the information.
- California Consumer Privacy Act Notice
The California Consumer Privacy Act (“CCPA”), which provides California Consumers certain rights regarding their Personal Information (“PI”) as those terms are defined in the CCPA, became effective on January 1, 2020. As of that date, the California Attorney General had not completed the rule making process to establish the regulations for businesses to implement the law.
In the meantime, we are providing you with notice of the personal information we collect and our purposes for that collection for data that may be subject to the CCPA (“CCPA Notice”). This CCPA Notice does not cover information that is outside of the scope of the CCPA. This notice also does not apply to data collected from employees, applicants or contractors or to data collected from individuals acting as representatives of another business in connection with business communications or transactions.
We may collect and share the following personal information that may be subject to the CCPA for the following purposes:
|Category of PI||Purposes for Collection||Categories of Third Parties with whom PI is shared|
|1. Identifiers and Personal Records
(e.g., name, phone number, e-mail address, IP address)
|Providing our services, improving our services, quality assurance, marketing, security, internal analytics and reporting||Vendors, data analytics partners, advertising partners|
|2. Internet Usage Information (e.g. information regarding your interaction with our services)||Security, internal analytics and reporting||Vendors, data analytics partners, advertising partners|
|3. Geolocation Data||Security, internal analytics and reporting||Vendors, data analytics partners, advertising partners|
|4. Inferences from PI Collected (e.g. your preferences, your likelihood of interest in certain of our services)||Providing our services, improving our services, marketing||Vendors, data analytics partners, advertising partners|
We do not knowingly “sell” personal information that we collect from you, in accordance with the definition of “sell” in the CCPA, and will treat personal information we collect from you as subject to a do not sell request.
California Consumers have the right to exercise the privacy rights under the CCPA. California Consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA. Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI.
We will make commercially reasonable efforts to identify Consumer PI that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.
If you are a California Consumer and would like to register a request under your “right to know about personal information collected, disclosed or sold” (including right to obtain copies of specific pieces and/or information about categories of personal information practices), “right to request deletion of personal information,” or “right to opt-out of the sale of personal information,” or otherwise exercise any of your other privacy rights under the CCPA, you can contact us at firstname.lastname@example.org and we will respond to your request as and when we have regulatory guidance on how to properly verify you and respond to your requests and are able to do so.
You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
- The categories of PI we have collected about you.
- The categories of sources from which we collected your PI.
- The business or commercial purposes for our collecting or selling your PI.
- The categories of third parties with whom we have shared your PI.
- The specific pieces of PI we have collected about you.
- A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
- A list of the categories of PI sold about you in the prior 12 months, or that no sale occurred. If we sold your PI, we will explain:
- The categories of your PI we have sold.
- The categories of third parties to which we sold PI, by categories of PI sold for each third party.
You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have collected in the period that is 12 months prior to the request date and are maintaining.
Please note that PI is retained by us for various time periods, so we may not be able to fully respond to what might be relevant going back 12 months prior to the request.
Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Note also that we are not required to delete your PI that we did not collect directly from you.
You may alternatively exercise more limited control of your PI by instead exercising one of the more limited opt-outs, including unsubscribing from email newsletters.
We will revise this CCPA Privacy Notice from time to time as implementing regulations further develop and come into effect and we are able to provide you with better information on your CCPA rights and how to exercise them.
- Nevada Residents. Nevada residents have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. This site does not engage in activity that triggers the opt-out requirements defined in Nevada Revised Statutes Chapter 603A, beyond the purpose of the services offered on this site. However, you can exercise this right by contacting us at email@example.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. We will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
- Opting Out
If datalignadvisory.com sends emails to you, you may opt out of receiving such e-mails at any time by responding to the opt-out link provided on all such e-mail communications from datalignadvisory.com.
Datalign Advisory, LLC
One Kendall Square, Suite B2102
Cambridge MA 02139